Privacy Policy

Effective date: July 25, 2026 · Last updated: July 25, 2026

This Privacy Policy explains how Gallarus Advisors, LLC ("Gallarus," "we," "us," or "our") handles personal data in connection with the website at thehermitsway.com (the "Site") and the Hermit's Way: Tarot Journal application (the "App," or "The Hermit's Way").

The Hermit's Way is a reflective tarot practice designed to help you notice more clearly — through images, a real question, writing, and reflection. It is not fortune-telling.

1. Who we are

The controller of the personal data described in this policy is Gallarus Advisors, LLC, 456 Glenbrook Rd, Ste 4, Unit #1393, Stamford, CT 06906 USA. Email: hello@gallarusadvisors.com.

2. Our privacy approach

The Hermit's Way is designed to collect as little personal data as possible.

The Hermit's Way is local-first: your reflections, journal entries, reading history, meditation session logs, and related App data are stored on your device. If you enable iCloud sync within the App, this data is also synchronized to your private Apple iCloud account using Apple's CloudKit service so it remains available across your Apple devices. iCloud sync is optional and can be enabled or disabled at any time.

Gallarus Advisors does not have direct access to your private CloudKit database.

When you choose to use the optional Deepen feature, only the information necessary to provide the conversation is securely transmitted to our AI provider.

We do not sell personal data. We do not use advertising. We do not engage in cross-app tracking. The Site uses privacy-respecting, cookieless analytics.

3. Data we process

3.1 On the Site

Analytics. We collect aggregate, non-identifying website usage statistics without cookies and without profiling individual visitors.

Contact information. If you contact us by email, we process the email address and message you provide in order to respond.

3.2 In the App

Reflections and practice data. Your reflections, journal entries, reading history, meditation session logs, deck selections, and related App data are stored on your device using Apple's local storage. If you enable iCloud sync within the App, this data is also synchronized to your private Apple iCloud account using Apple's CloudKit service so it remains available across your Apple devices. Gallarus Advisors does not have access to your private CloudKit database.

Deepen. When you use Deepen, the reflection you choose to submit, together with the conversation history required to provide continuity within the reflective dialogue, is securely transmitted to Anthropic to generate a response. We process this information solely to provide the Deepen experience. We do not use your reflections or conversations to train public AI models.

Deepen memory (Hermit's Way Plus subscribers). For Hermit's Way Plus subscribers, Deepen retains a synthesized summary of themes from previous sessions to provide continuity across future reflective conversations. This memory is stored alongside your other App data and follows the same local-first, optional iCloud sync model described above. You may view, delete, or disable this feature within the App at any time.

Subscription status. Purchases of Hermit's Way Plus are processed through Apple App Store In-App Purchases. We do not receive or store your payment card information. We receive subscription status information necessary to unlock paid features.

4. How we use data and our legal bases

Where the GDPR or UK GDPR applies, we rely on the following legal bases under Article 6:

• operating and securing the Site and App — legitimate interests;
• providing optional CloudKit synchronization — performance of a contract;
• providing the Deepen feature you request — performance of a contract and, where applicable, your consent;
• maintaining Deepen conversation continuity — performance of a contract;
• responding to communications — legitimate interests and/or consent;
• managing subscriptions — performance of a contract;
• understanding aggregate Site usage — legitimate interests.

Where we rely on consent, you may withdraw it at any time without affecting prior processing.

Special category data. Because reflections may contain information relating to emotions, health, beliefs, or other sensitive subjects, your use of Deepen may involve processing special category personal data under applicable law. Where required, we rely upon your explicit consent for such processing.

5. Cookies and tracking

The Site does not use advertising cookies or cross-site tracking. The App does not include third-party advertising. The App does not use Apple's App Tracking Transparency framework because it does not track users across apps or websites.

6. Who we share data with

We share personal data only with service providers that help us operate The Hermit's Way. These include:

Apple CloudKit — if you enable iCloud sync, stores your reflections, journal entries, meditation session logs, and reading history within your private iCloud account so they remain synchronized across your Apple devices.

Anthropic — processes information submitted through Deepen to generate reflective responses.

Vercel — hosts the Site and provides aggregate website analytics.

Google — processes email you send to us.

Apple — processes App downloads, subscriptions, and payments through the App Store.

We do not sell personal data. We do not share personal data for cross-context behavioral advertising. We may disclose information when required by law.

7. International data transfers

Gallarus Advisors is located in the United States. Our service providers may process information in the United States and other countries. Where personal data is transferred from the European Economic Area or United Kingdom, we rely upon appropriate legal safeguards such as Standard Contractual Clauses or another lawful transfer mechanism.

8. Data retention

Your reflections, journal entries, reading history, meditation session logs, and related App data remain on your device (and, if you have enabled iCloud sync, in your private iCloud account) until you delete them from The Hermit's Way, uninstall the App, or remove them through your Apple account.

Deepen conversation memories remain until you delete them or disable the feature.

We retain website communications only as long as reasonably necessary for the purposes described in this policy or as required by law.

9. Your rights

Depending on applicable law, you may have the right to:

• access your personal data;
• correct inaccurate information;
• request deletion of your personal data;
• restrict or object to processing;
• receive a copy of your data;
• withdraw consent where processing relies upon consent; and
• lodge a complaint with your local data protection authority.

Because your App data is stored on your device (and, if you have enabled iCloud sync, in your private iCloud account), you may delete your reflections, reading history, and Deepen memories directly within the App or through your Apple account. To exercise any other privacy rights, contact us at hello@gallarusadvisors.com.

10. Children

The Hermit's Way is intended for adults and is not directed toward children under 18. We do not knowingly collect personal data from children. If you believe a child has provided personal information, please contact us so we can delete it.

11. Security

We use reasonable technical and organizational measures to protect personal data. Data stored on your device is protected by iOS's built-in security. Data synchronized through CloudKit is protected by Apple's security infrastructure. Communications with Anthropic occur over encrypted connections. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. Third-party services

The Site and App may link to third-party websites or services, including the Apple App Store. Those services operate under their own privacy policies, which we do not control.

13. US state privacy rights

Residents of certain US states, including California, may have additional rights regarding their personal data under applicable law. To exercise those rights, contact hello@gallarusadvisors.com.

14. Changes to this policy

We may update this Privacy Policy from time to time. The current version will always be available on our website with the revised "Last updated" date. If we make material changes, we will take reasonable steps to notify users.

15. Contact

Gallarus Advisors, LLC, 456 Glenbrook Rd, Ste 4, Unit #1393, Stamford, CT 06906 USA. Email: hello@gallarusadvisors.com.